Williams v. Bexar County District Attorneys Office

CourtDistrict Court, W.D. Texas
DecidedJuly 21, 2022
Docket5:22-cv-00257
StatusUnknown

This text of Williams v. Bexar County District Attorneys Office (Williams v. Bexar County District Attorneys Office) is published on Counsel Stack Legal Research, covering District Court, W.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Williams v. Bexar County District Attorneys Office, (W.D. Tex. 2022).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION

JOHN B. WILLIAMS III,

Plaintiff,

v. Case No. SA-22-CV-00257-JKP

BEXAR COUNTY DISTRICT ATTORNEY’S OFFICE, JOE GONZALES, ALEXANDRA ZEPEDA, TIFFANY MILLER, AND BRANDON RAMSEY,

Defendants.

MEMORANDUM OPINION AND ORDER Before the Court is a Motion to Dismiss filed by the Bexar County District Attorney’s Office, Bexar County District Attorney Joe Gonzales, and Bexar County Assistant District Attorney Brandon Ramsey (“Bexar County Defendants”). ECF No. 7. Upon consideration, the Court concludes the Bexar County Defendants’ Motion to Dismiss is GRANTED. This case is DISMISSED WITHOUT PREJUDICE for lack of subject matter jurisdiction. Factual and Procedural Background Appearing pro se, Plaintiff John B. Williams III filed suit against the Bexar County Defendant-Movants and two former Bexar County Assistant District Attorneys, Alexandra Zepeda and Tiffany Miller, regarding the Bexar County District Attorney’s Office’s handling of a 2019 criminal matter in which Williams was the defendant. Specifically, Williams alleges the court appointed him counsel in spite of his stated desire to proceed pro se—and appointed counsel was biased because they worked on the prosecution side of a 1999 criminal case brought against him. He further alleges his temporary confinement during the coronavirus pandemic was unduly punitive because of the risk of contracting the virus while confined. Williams alleges the Bexar County Defendants should have objected to what he perceives to be improper appointment of counsel. He further suggests the Bexar County Defendants’ support of his confinement was

problematic, the Bexar County Defendants failed to provide documents he requested, and DA Gonzales has failed to make good on his campaign pledge to reform the office. Williams cites several Federal and State criminal statutes as the bases for his claim, as well as Texas statutes dealing with open records and referral of Constitutional matters to the Attorney General. He requests relief in the form of an investigation and $5 million in damages. The Bexar County Defendants moved to dismiss Williams’ complaint, both on jurisdictional grounds and on the merits. To provide leniency, the Court deferred ruling on the Motion and directed Williams to show cause why the Court should not dismiss his case for lack of jurisdiction. ECF No. 15. Williams responded on July 8, 2022, arguing the case should be

allowed to proceed because civil and criminal matters can be joined in the same action. ECF No. 16. Legal Standard Federal Rule of Civil Procedure 12(b)(1)1 authorizes dismissal of a case for lack of subject matter jurisdiction when the district court lacks statutory and constitutional power to adjudicate the case. Home Builders Ass’n of Miss., Inc. v. City of Madison, 143 F.3d 1006, 1010 (5th Cir. 1998). If a Rule 12(b)(1) motion is filed in conjunction with other Rule 12 motions, the

1 Although their Motion cites to Federal Rule of Civil Procedure 12(b)(6), the Court construes the Bexar County Defendants’ standing argument as a Federal Rule 12(b)(1) argument because it raises jurisdictional issues. Court will consider the jurisdictional attack under Rule 12(b)(1) before addressing any attack on the legal merits. Ramming v. United States, 281 F.2d 158, 161 (5th Cir. 2001). The jurisdiction of federal courts is circumscribed by the limits set forth in Article III of the Constitution. Valley Forge Christian Coll. v. Ams. United for Separation of Church and State, Inc., 454 U.S. 464, 471 (1982). Article III legitimizes the use of judicial power “to declare

the rights of individuals and to measure the authority of governments” in the resolution of “cases” and “controversies.” Id. For that reason, a federal court must dismiss a case for lack of subject matter jurisdiction if the court lacks “the statutory or constitutional power to adjudicate the case.” Home Builders Ass’n of Miss., 143 F.3d at 1010 (quoting Nowak v. Ironworkers Local 6 Pension Fund, 81 F.3d 1182, 1187 (2d Cir.1996)). A court “must presume that a suit lies outside [its] limited jurisdiction, and the burden of establishing federal jurisdiction rests on the party seeking the federal forum.” Howery v. Allstate Ins. Co., 243 F.3d 912, 916 (5th Cir. 2001). The Fifth Circuit has long held that, under Federal Rule 12(h)(3), the federal courts “have the responsibility to consider the question of subject matter jurisdiction sua sponte if it is not raised

by the parties and to dismiss any action if such jurisdiction is lacking.” Giannakos v. M/V Bravo Trader, 762 F.2d 1295, 1297 (5th Cir. 1985). Discussion In this case, the Bexar County Defendants challenge the Court’s subject matter jurisdiction on grounds of constitutional standing, official immunity, prosecutorial immunity, and because the county is a non-jural entity. Standing resolves this case, so the Court does not address the Bexar County Defendants’ other arguments. Constitutional standing, which is a plaintiff’s personal stake in the outcome of the case, is an “essential and unchanging part of the case-or-controversy requirement of Article III.” Davis v. Fed. Election Comm’n, 554 U.S. 724, 733 (2008) (quoting Lujan v. Defenders of Wildlife, 504 U.S. 555, 560 (1992)). “To establish Article III standing, a plaintiff must show (1) an ‘injury in fact,’ (2) a sufficient ‘causal connection between the injury and the conduct complained of,’ and (3) a ‘likel[ihood]’ that the injury ‘will be redressed by a favorable decision.’” Susan B. Anthony List v. Driehaus, 573 U.S. 149, 157–58 (2014); Henderson v. Stalder, 287 F.3d 374, 378 (5th

Cir. 2002). “The party invoking federal jurisdiction bears the burden of establishing each of these elements.” Lujan, 504 U.S. at 560–61; accord, Clapper v. Amnesty Int’l USA, 568 U.S. 398, 411–12 (2013). A plaintiff must show an “actual or imminent,” “concrete and particularized” injury in fact. Friends of the Earth, Inc. v. Laidlaw Env’t. Servs., Inc., 528 U.S. 167, 180 (2000). “Central to assessing concreteness is whether the asserted harm has a ‘close relationship’ to a harm traditionally recognized as providing a basis for a lawsuit in American courts—such as physical harm, monetary harm, or various intangible harms.” TransUnion LLC v. Ramirez, 141 S.Ct. 2190, 2200 (2021). Williams alleges his 2019 criminal prosecution was part of a conspiracy

against him dating back to 1999. He further alleges he was inappropriately appointed counsel and jailed. He does not, however, explain what injury he suffered as a result. Construed liberally, Williams appears to suggest he was injured by having to defend himself in the 2019 criminal matter and he suffered from a fear of exposure to coronavirus in confinement. These injuries are not sufficiently concrete and particularized to establish standing in federal court.

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Howery v. Allstate Ins Company
243 F.3d 912 (Fifth Circuit, 2001)
Henderson v. Stalder
287 F.3d 374 (Fifth Circuit, 2002)
Lujan v. Defenders of Wildlife
504 U.S. 555 (Supreme Court, 1992)
Davis v. Federal Election Commission
554 U.S. 724 (Supreme Court, 2008)
Giannakos v. Bravo Trader
762 F.2d 1295 (Fifth Circuit, 1985)
Clapper v. Amnesty International USA
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Williams v. Bexar County District Attorneys Office, Counsel Stack Legal Research, https://law.counselstack.com/opinion/williams-v-bexar-county-district-attorneys-office-txwd-2022.